One of our title companies would like their Incoming Funds Transfer Notice to include the account number for the originator. Our processor does not make that field available for us to add to our notice as they say it is a privacy issue to disclose that information. The client says that "other banks" provide that information (wells fargo I believe), and so I would like to see what other banks are doing and whether I should pursue it further with the processor or tell the client that we can't do it. I really can't see why they would need that but since we don't want to lose the business we would like to accommodate the request unless it really is a privacy issue.

Provide your processor with a copy of Question 2. Their "shortstopping" the account number information is a violation of their responsibilities under the travel rule.

An intermediary financial institution must pass on all of the above listed information, as specified in the travel rule, it receives from a transmittor's financial institution or the preceding intermediary financial institution...

Thank you so much for that response Ken. I have passed that along to the processor and so let's see what happens. I like when I can quote FinCen in my case

Unless I'm misunderstanding, the processor just isn't providing the Originator's account number on the notice, not the actual wire, correct?

So the Title Company gets say, an email notification stating that such-and-such wire was processed, amount, etc. They want the Originator account number to show on that. So, I can see where the processor is coming from in not wanting to provide that information but I believe they could show just the last 4 digits and not disclose confidential information. At least, that's the way we have our wire notifications set up.

If this is not what you mean and, in fact, the processor is stripping the information from the actual wire transfer within their system prior to sending it to you, then what Ken said.

Our processor does provide the information to us in the wire but not on the notice so we end up having to communicate that information to the client manually which is very time consuming. They responded to us that they do not interpret the guidance to mean that we must provide it along to the customer so it would be custom programming which is billable. That's been my experience in the past with this processor that unless there is guidance that is crystal clear with no room for interpretation, they tend to interpret regulations to their advantage and any changes are billable custom changes.

Here is the response from the processor "After reviewing the FinCEN “Travel Rule” guidance from 2010, and we agree that the “account number of the transmittor (if used)” must be included in the transmittal order, however, it does not stipulate that it should be disclosed in the customer’s notice of incoming wire. Since we have not been able to find any guidance on the contents of the customer notice, we cannot say that it is a requirement to include the transmittor’s account number in it. .... the transmittal order is the electronic method of passing the wire information from one financial institution to the other. This is different from the notice that is given to the customer receiving the incoming wire."

So since they don't have the same interpretation as we do they said it will be a 15 hour custom programming fee. SMH!